AIG’s Global Anti-Corruption Policy and accompanying Global Anti-Corruption Standards and Due Diligence Procedures for Third Parties, issued by AIG’s Corporate Compliance Group and approved by senior management:

Apply to all employees and ensure that AIG business is conducted in compliance with all applicable anti-corruption laws and regulations in the U.S. and in other jurisdictions in which AIG operates or does business

Set forth minimum requirements for employees to follow to ensure no bribery or corruption-related activities occur when employees directly or indirectly interact with U.S. and non-U.S. Government Officials, Other Persons and Third Parties acting on AIG’s behalf

Describe the roles and responsibilities of employees and Compliance as they relate to the Policy, including reporting violations, reviewing potential issues and oversight of the program

Outline potentially permissible expenditures and activities that may be allowed under certain circumstances, including gifts, meals and other hospitality for Government Officials, political contributions, charitable contributions, Government Officials as customers and Government Officials as employees

Require that all third parties that have, or may have, interactions with Government Officials or Government Entities on AIG’s behalf undergo appropriate due diligence prior to being retained or doing business with AIG

AIG’s Global Anti-Corruption Compliance Program includes the following elements:

An annual compliance risk assessment program

Periodic anti-corruption training for all AIG employees

Gift and entertainment reporting requirements

Requirements related to the hiring of Government Officials or relatives thereof

Records retention requirements